Ethics and Compliance

Our Commitment

Throughout our history, operating with integrity has been a guiding principle for us at Dover. This commitment to integrity, and to operating in keeping with the highest ethical standards, has earned us the trust of our customers, shareholders, employees, and the communities where we work. We care deeply about maintaining this trust, we stay vigilant, and we actively support our culture of operating with integrity through our ethics and compliance program.

Our Code of Conduct

Our Code of Conduct (our “Code”), which is evaluated and updated on a regular basis, embodies our high ethical standards and provides the framework for our conduct, our interactions with others, and our decision-making. The Code applies to all of our employees, regardless of location, position or operating company, and is published in 18 different languages. It is the foundation on which our ethics and compliance policies are built and together, the Code and our policies represent a significant element of our ethics and compliance program.

Integrity by Example

We expect our leaders to model and reinforce integrity, and that all of our employees will exhibit integrity in carrying out their responsibilities.

Our Compliance Program

Our compliance program is led by our Chief Compliance Officer and a dedicated team of compliance professionals around the world, both at the corporate and operating company level. This team of compliance professionals is supplemented by our Compliance Champion Program, a network of compliance-trained points of contacts at facilities around the world, which extends compliance knowledge and focus throughout our organization.

In carrying out the mission of our compliance program, we seek to understand our key risks in order to most effectively and efficiently tailor the program to mitigate those risks and deploy our compliance resources accordingly. Toward that end, we measure our progress and identify areas for growth through a comprehensive compliance risk assessment process. This annual risk assessment drives key decisions, including when and how we update our policies, what training we provide and to whom, and what programs we put in place or modify.

Another essential aspect of our program is the training and empowering of compliance personnel and champions at our operating companies and facilities around the world. We hold an annual compliance conference to drive continuous improvement, conduct quarterly telephonic meetings with compliance personnel and champions to train and share best practices, and hold regional compliance group meetings for localized training of compliance personnel and champions.

Policies & Controls

In addition to the guiding principles of our Code, we maintain and regularly review ethics and compliance policies that govern our activities around the world. Some of these include:

• A Related Person Transactions Policy
• A Dover Corporation Communications & Complaints Policy
• A Code of Ethics for Dover’s CEO and Senior Financial Officers
• A Federal Supplement to the Code, which applies to all employees, agents, contractors, and directors who market, sell to or work on projects with the U.S. government or interact with U.S. government official
• Guidance regarding conflicts of interest
• A Global Anti-Corruption Policy, which sets forth our global anti-bribery commitment and applies to employees and certain third parties who act on our behalf
• A Securities Trading and Confidentiality Policy that governs trading in Dover securities and the protection of confidential information
• Guidance regarding third party due diligence

Finally, we seek to conduct business only with third parties who share our commitment to the values and principles in our Code, including those standards laid out in our Supplier Code of Conduct. We also maintain a comprehensive compliance vetting program that screens third parties who provide goods and services to Dover and its operating companies. The program evaluates potential and existing business partners based on factors such as the country in which they do business, the interactions they may have with government agencies, and the nature of their compensation or the level of business they do with Dover companies, and sets screening standards for each third party based on the level of risk. We then rescreen our third parties on a regular cadence to ensure that as business realities may change, so will the corresponding screening standards.

Encouraging Employees to Speak Up

Due to our global presence, we recognize that laws, regulations, business practices, and customs can vary greatly from one country to the next. If a situation arises where our Code, our policies, or the laws of any country are in conflict, we encourage our employees to seek guidance. In our Code training, and in all live training sessions, employees are reminded that whenever they have a concern, they have multiple avenues to raise their concerns in a manner most comfortable to them. Those avenues include their direct supervisor, their local human resources partner, their local compliance manager, or the Dover Law Department or compliance team.

In addition, we maintain a Global Hotline that can be used by any person to report issues or concerns relating to our standards of business ethics and compliance, and to do so anonymously if they so choose (unless prohibited by local law). This hotline is available 24 hours a day, 7 days a week, in 17 different languages, and its availability is communicated to our employees through the Code, in live and online training sessions, in our quarterly compliance newsletter, and through posters that are displayed at every Dover facility.

Non-retaliation Policy

Dover has a strict non-retaliation policy. We treat reports of suspected improper behavior confidentially to the fullest extent possible and will not tolerate retaliation against those who report suspected misconduct in good faith.

Compliance Training

Dover’s comprehensive compliance training program is known as “IntegrityCounts”. Based upon key risk areas identified through our compliance risk assessment process, we regularly refresh both the substance and methods of compliance training in order to help our global workforce and our business partners understand and comply with the law, our Code, and our other compliance policies. Our training plan is set on a three-year rolling schedule but is reviewed annually, and is matrixed to consider factors such as geography and job function. We use a combination of online, webinar, and live training sessions to effectively reach our workforce.

At Dover, IntegrityCounts

To foster an ethical culture, we publish our “IntegrityCounts” newsletter to our employees once a quarter. In this newsletter, which is published in 7 languages, we share policy updates, best practices, and tips for our employees to continuously maintain professional integrity – no matter their role or location.

Our online training program assigns courses to online employees based on a risk-focused assessment of their roles and locations. In 2021, the assigned courses covered our Code, Conflicts of Interest, Reporting Concerns, Anti-Slavery/Supply Chain Matters, Trade Compliance, Data Privacy, Data Security, Fair Competition, Anti-Corruption, Careful Communication, Confidential Information, Insider Trading, and Records Management.

We supplement this online training program with webinars that are designed to provide more in-depth learning on laws and regulations covering various aspects of our business in the jurisdictions where we operate. We also believe live training is an effective and important component of our compliance program. Accordingly, we conduct a live training program that delivers in-person or virtual training on key risks to employees in higher-risk regions, in select job functions or with responsibilities involving higher-risk regions, as well as to those employed at businesses newly-acquired by Dover. In addition, our operating company compliance professionals deliver live training at operating company meetings that can impact high risk groups, such as sales meetings for personnel who work in, or sell into, high risk countries.

Ethics and Compliance Highlights

• Employees are guided by the values and principles embodied in our Code of Conduct, which is published in 18 different languages
• Substantially all online employees completed our 2021 Code of Conduct e-training
• Substantially all online employees completed our 2021 anti-corruption e-training
• Organization’s anti-corruption policies and procedures have been communicated to 100% of governance body members
• 100% of our operations are assessed for risk, including corruption. Every operating company is required to do so regularly. We have an annual risk and mitigation scoring process, and we require developing action plans for new and emerging risks